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EA Consultation: Technically Competent Managers (TCM) attendance requirement

The EA currently have a consultation out on proposed changes to the technically competent managers (TCM) attendance requirements, which will include for AD plants.  

Questionnaire can be found here 

Under Environmental Permitting conditions the Environment Agency require that sites have nominated technically competent manager(s) (TCMs) on site for a specified amount of time a week. This is called the attendance requirement. 

However, the EA will be making changes to these requirements and they way they are determined to “to simplify the requirements for both industry and regulators and provide greater clarity of what the attendance requirements are.” 

Currently the attendance requirement is worked out based on an ‘Operational Risk Appraisal’ (OPRA) which considers the risk of location, emissions and complexity and gives a percentage figure for how long a TCM must be onsite each week. For an AD plant operating to a standard rules permit this is 20%.  

The EA aim to: 

  • Make it clearer and easier than the current OPRA guidance to determine the attendance requirement. 
  • Ensure that poorly performing plants get additional support and oversight from TCM(s) 
  • Clear up attendance requirements for 24-hour operations like AD plants- i.e. should TCM attendance be 20% of all operational hours or just staffed hours.  

We welcome any feedback and views on this to aid the EA in shaping future requirements. 

Full details of the consultation can be found here:  

Further detail on what the TCM requirements currently are can be found here. 

The consultation closes on 9th August 2021 and ADBA will be aiming to have a response written by 4th August 2021. 

Please email your responses to and/or fill in this questionnaire

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